Policy to

Combat Corruption and Money Laundering

This Policy also aims to guide our employees and service providers on the behavior to be maintained when conducting any business related to our organization, always seeking to combat Corruption and Money Laundering.

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1 - Objective

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Our objective is to build a strong and cohesive institution that adheres to norms capable of deterring harmful conduct not only within the organization but also in society as a whole, fostering an anti-corruption culture.

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We aim to establish well-defined relationships, including international ones, with a focus on combating corruption.

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We will create mechanisms for preventing money laundering and fighting against corruption while complying with the existing legal frameworks in the country.

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Furthermore, we encourage suppliers to not only commit to our organization's code of conduct but also implement their own systems/mechanisms for compliance.


This policy applies to all employees and service providers.


Public Agent(s): those who hold a public position. According to the Law of Administrative Improbity (Law No. 8429/92), a Public Agent is anyone who exercises, even temporarily or without remuneration, a mandate, position, employment, or public function through election, appointment, designation, hiring, or any form of investiture or bond.

Compliance Channels: channels provided by Ikatec and affiliated companies for employees and third parties to ask questions about compliance and report suspected violations of the Code of Ethics and other policies. Contact can be made via email at compliance@ikatec.com.br. Reports are confidential and can be made anonymously.

Code of Ethics: the Ikatec Code of Ethics that, together with other internal policies and norms, establishes the expected conduct for employees and service providers.

Employees: all those who work on behalf of or represent Ikatec, including its partners, associates, directors, and employees.

Corruption: the act or effect of corrupting someone or something with the purpose of obtaining illicit advantages.

Due Diligence: the detailed examination of information and documents of an individual or legal entity for specific purposes (general contracts, etc.).

Compliance Group:a group composed of representatives from the Board of Directors, legal department, finance, and human resources, responsible for editing, revising, and interpreting the Code of Ethics and other policies, managing compliance channels, and investigating suspicions of deviations.

Ikatec: the business entity and all its subsidiary, controlled, affiliated, or integrated companies.

Money Laundering: the process by which resources originating from illegal activities are transformed into assets that appear to have a legal origin.

Anti-Corruption Laws: law No. 12,846/2013, which deals with the administrative and civil liability of legal entities for acts against public administration, both national and foreign. For the purposes of this policy, the definition also includes any other norms and regulations that should be read together for interpretation and application, including the Brazilian Penal Code and international norms internalized by Brazil.

Anti-Money Laundering Laws: law No. 9,613/1998, which deals with the crimes of money laundering or concealment of assets, rights, and valuables and the prevention of the use of the financial system for illicit purposes. For the purposes of this policy, the definition also includes any other norms and regulations that should be read together for interpretation and application, including the Brazilian Penal Code and international norms internalized by Brazil.

Bribery: The act of inducing someone to perform a certain action in exchange for favors or benefits not provided for by law.

Undue Advantage: any advantage to which the Public Agent is not entitled due to their public function.


4.1 - Bribery and Corruption:

Every employee and service provider is prohibited from offering bribery and engaging in any act of corruption in the course of their activities.

One of our guidelines is to facilitate the access of state control bodies to databases that allow the identification of possible occurrences of money laundering. Another guideline is to establish mechanisms that aid in the identification and empower our employees to identify suspicious transactions.

The Anti-Corruption Law prohibits the following conducts:
I - Promising, offering, or giving, directly or indirectly, undue advantage to a public agent or a third party related to them;
II - Clearly financing, funding, sponsoring, or in any way subsidizing the practice of illicit acts under this Law;
III - Clearly using an intermediary natural or legal person to conceal or disguise their real interests or the identity of the beneficiaries of the acts practiced;
IV - Regarding bids and contracts:
a) Frustrating or defrauding, through an agreement, combination, or any other means, the competitive nature of a public bidding procedure;b) Preventing, disturbing, or defrauding the performance of any act of a public bidding procedure;c) Eliminating or seeking to eliminate a bidder, through fraud or offering any type of advantage;d) Defrauding a public bidding or the contract arising from it;e) Fraudulently or irregularly creating a legal entity to participate in a public bidding or enter into an administrative contract;f) Obtaining undue advantage or benefit, fraudulently, from modifications or extensions of contracts entered into with the public administration, without authorization by law, in the public bidding invitation or in the respective contractual instruments; org) Manipulating or defrauding the economic-financial balance of contracts entered into with the public administration;

V - Hindering the investigation or inspection activities of public bodies, entities, or agents, or intervening in their actions, including within the scope of regulatory agencies and the entities that supervise the national financial system.

No employee or service provider will be penalized for delays or loss of business resulting from their refusal to pay bribes or engage in any act of corruption.

4.2 - Facilitating Payments:

Facilitating payments are those without legal authorization, made to Public Agents or individuals indicated by them, to ensure or expedite the execution of any act. Ikatec prohibits facilitating payments.

4.3 - Business Partners:

We do not authorize any business partner to engage in any act that could be understood as corruption or violate the law on behalf of or in representation or defense of Ikatec's interests.

All contracts signed must include clauses ensuring compliance with Anti-Corruption Laws, Anti-Money Laundering laws, and acceptance of our Code of Ethics.

4.4 - Philanthropic Contributions:

All requests for philanthropic contributions must be submitted for analysis and deliberation by the Compliance Group via email at compliance@ikatec.com.br .

The decision to make contributions will take into account financial aspects, the regularity and integrity of the beneficiary entity, and its alignment with Ikatec's objectives and values or its potential to contribute in an easily identifiable manner.

4.5 - Political Contributions:

Ikatec, respecting the freedom and personal political convictions of each citizen, has a policy of not contributing to or financing candidates for elective positions. Ikatec does not make donations to political parties or support individuals seeking public office; all relationships with the government at any level are done in accordance with the law.

Ikatec's principle is not to engage with third parties or hire employees who support parties connected to or involved in illegal or dubious activities, whether national or foreign.

4.6 - Union Contributions:

We respect the right to union membership as long as resources and assets of Ikatec are not used for that purpose. Company and employee contributions to unions, whether voluntary or compulsory, comply with applicable legislation. We do not make donations to unions.

4.7 - Sponsorship:

Sponsorship only occurs, likewise, after a thorough analysis of information, documents, and the integrity of the entity to be sponsored, as well as whether the events are in any way related to Ikatec's social objectives.

4.8 - Money Laundering:

Employees and service providers must remain vigilant and refuse to engage in any act when they suspect its legitimacy and legality. Suspicions must be reported to Ikatec.

Behaviors that may indicate attempted money laundering:

· Requesting payments in cash when it is not the only possible means to fulfill the obligation;· Requesting payments to multiple beneficiaries;· Requesting payments through unusual means;· Requesting payments to a person different from the one listed as the supplier or service provider.

4.9 - Record Keeping and Accounting:

We conduct our business with integrity, ethics, transparency, and good faith. We place importance on compliance with tax and accounting legislation. Accurate and technically sound financial and accounting records are ways to establish truth and transparency in our transactions.

It is the duty of employees and service providers to document and maintain records of financial operations under their responsibility, including those related to expense reimbursement, advances, and the use of corporate cards.

False, incomplete, or misleading documents or information should not be included in Ikatec's books and records.

4.10 - Red Flags:

Employees and service providers should be attentive to the following situations:

· History of Corruption;· Requesting excessive commissions paid in cash or through unusual means;· The counterpart is controlled by a Public Agent or has a close relationship with a Public Agent or the government;· The counterpart is recommended by a Public Agent;· Provision or request of dubious invoices or other documents;· Refusal to include references to Anti-Corruption Laws or Anti-Money Laundering in the contract;· Proposal of unusual financial schemes, such as requesting payment in a different country from where the service is provided or into multiple bank accounts;· The counterpart has no establishment or employees.In these cases, employees and service providers must report to Ikatec through compliance channels.


Employees and service providers must:

· Adhere to the Code of Ethics and this policy;· Ensure that business partners are aware of the values expressed in the Code of Ethics and this policy, and conduct their activities in accordance with these values;· Report suspicions of policy violations through compliance channels.

Managers must:

· Reinforce this policy through communication;· Ensure that their teams comply with this policy;· Ensure that their teams participate in training on the Code of Ethics and other institution policies.


In addition to violating ethical principles, illicit conduct can compromise the organization's image and reputation and undermine its economic value, sustainability, and longevity. Engaging in illegal acts may result in civil, administrative, and criminal liability for the organization and its responsible parties.

To keep the organization in line with the values expressed here and compliant with the law, in situations not covered by this policy, the Compliance Group should be consulted through compliance channels for resolution or guidance.

This policy is linked and an integral part of the Code of Ethics and should be interpreted together with other policies related to the Code.

The review and update of this policy are the responsibility of the Compliance Group and can be done at any time. Violations of this policy subject the offenders to the sanctions provided in Ikatec's Internal Regulations and Code of Ethics, without prejudice to any possible legal actions.

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